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PRIVACY POLICY

WHO ARE WE AND HOW YOU CAN CONTACT US

Contact details of the Data Controller: UAB “KlasJet”, Legal entity code 303163347, address Dariaus ir Girėno str. 21A, Vilnius, Republic of Lithuania, phone number +37052525581, email address [email protected] (hereinafter “We”, “Ours”, “Company”, “KlasJet”) process the personal data of its’ customers, potential customer, employees, candidates to employees, suppliers, partners etc. (hereinafter referred to as the you, your) personal data in accordance with the provisions of the legal acts regulating the legal protection of personal data and applying the highest technical and legal standards of protection and taking all necessary measures to prevent possible breaches of personal data protection. This Privacy Policy (hereinafter referred to as the “Privacy Policy“) sets out the basic rules for the collection, processing and storage of your personal data and other information related to you, the scope, purposes, sources, recipients of your personal data and your rights as a personal data subject and other important aspects of your use of the Company’s services. This information is important, so we hope you will read it carefully.

As used in this Privacy Policy, the term “personal data” (the “Personal Data”) means any information about you relating to you as a natural person, a data subject whose identity is known or can be directly or indirectly identified through the use of certain data (e.g. name, surname, personal identification number, address, telephone number, etc.).

In processing the personal data, we responsibly comply to the regulation No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), Law on the Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania and other directly applicable legal acts regulating the protection of personal data, as well as instructions from competent authorities.

In the event that you provide us with personal information other than your own (for example, identifying another person as a beneficiary), please inform them of this Privacy Policy and its contents.

If the user of the services is a legal entity, this Privacy Policy applies to natural persons whose personal data is transferred to us by a legal entity. The user must duly comply with Art. 14 of the GDPR. to inform data subjects (managers, beneficiaries, representatives, etc.) about the transfer of their personal data to the Company.

If you have any questions regarding this Privacy Policy or requests regarding the processing of your personal data, please contact our Data Protection Officer by email: [email protected].

By visiting the Company’s websites and / or using the information contained therein and / or our services, you acknowledge and confirm that you have read and understood this Privacy Policy.

TO WHOM THE PRIVACY POLICY APPLIES

This Privacy Policy applies to our website www.klasjet.aero and any service provided by the Company or other activities of the Company where personal data is being process.

The terms and conditions of the Privacy Policy apply to you every time you access the content and/or the service we provide, regardless of which device (computer, cell phone, tablet, TV, etc.) you are using.

This Privacy Policy does not apply to links to other entities websites provided on our websites; therefore, we recommend that you read the personal data processing rules applied on such websites.

WHAT PRINCIPLES DO WE COMPLY TO?

When processing your personal data, we:

  • comply with current and applicable legislation, including the GDPR;
  • we will process your personal data in a lawful, fair and transparent manner;
  • we will collect your personal data for specified, clearly defined and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;
  • take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
  • we will keep them in such a form that your identity can be established for no longer than is necessary for the purposes for which the personal data are processed;
  • we will not disclose or disclose personal data to third parties except as provided in the Privacy Policy or applicable law;
  • ensure that your personal data is processed in such a way as to ensure the appropriate security of personal data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing of personal data and against unintentional loss, destruction or damage. Contact details of our Data Protection Officer: [email protected].

WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS

The purpose of the processing of personal data. Why we process personal data? The categories of processed personal data. What kind of categories of personal data we process? On what legal basis do we process personal data? The period of processing
Administration of our website When you visit our website, data about your browsing on the Website is collected using cookies. We use necessary / technical cookies to ensure the proper functioning of the Website and / or other third-party cookies to improve your browsing experience (i.e., to consider your needs, to continuously improve the website and to make offers that suit your interests). Data using cookies and similar technologies related to Internet browsing, etc. are collected (processed) in accordance with Article 6 Part 1. a) of the GDPR, i.e., with your consent (except for necessary cookies). You can find more information about cookies and their storage terms on our website

 

https://klasjet.aero/cookie-policy/
Responding to your general enquiries or requests of information Our website or other public business channels provide com contacts where you can contact us to consult us on issues that concern you. We will accept, review, and respond to all your messages. If you contact us by e-mail, regular mail, or phone, we may process the following personal data of yours: name, surname, e-mail, postal address, and the text of the correspondence and / or attached documents. This data will be processed for the administration of your enquiry. Please note that we may need to contact you to provide with a reply to your enquiry so be sure to share accurate contact data of yours. All personal data you provide when communicating with us is used only for the purposes of reviewing, and responding messages, administering (managing) communication flows and providing you with a response. We will process the said personal data in accordance with Article 6 Part 1. a) of the GDPR, i.e., with your consent, which you express by contacting us by e-mail, mail, or phone. Communication with you will be handled until the enquiry is fully processed and stored for three years from the date of the last communication with you unless there is another legitimate purpose for storing it longer (e. g. business contract with you has been concluded and communication material can be considered as the proof of negotiation).

 
Drawing up and executing contracts for the purchase and sale of services We may process name, surname, contact information (e-mail address, phone number), position in the company you represent, signature, other information required for negotiations, concluding, and performing of contracts. We will process in accordance with:

– Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it.

– Article 6 Part 1. c) of the GDPR., i.e., we are subject to a legal obligation to keep contracts and accounting documents.

– Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest in asserting and / or defending our legal claims (where applicable).

 Contracts and accounting documents (in physical and/or electronic form) are kept for 10 years from the date of full performance of the contract.
Onboarding and due diligence procedure for counterparties Depending on whether a counterparty is a natural person or legal entity and if the latter depending on your status in the company, we may process the following personal data:

Name, surname, date of birth, nationality, occupation, valid ID/passport number, data on whether the client is a politically exposed person, residential and registered address details, phone number, e-mail address, bank information (account number), relationship with the third party (if payment will be made by the third party), source of funds/wealth (if payment will be made in cash), signature, role/position in the company, occupation, information about reputation from public sources.

We also process personal data collected within provided copies of documents: Identity Card or Passport; Official documents of authorities verifying the identity and the place of residence; Documentation proving the source of funds/wealth; Articles of Association authorizing the representative of a legal entity; Certificate of Incorporation or its equivalent; Certificate of Directors or copy of CEO (or other principal management body) appointment document.

 Personal data for onboarding and due diligence is processed in accordance with:
– Article 6 Part 1. c) of the GDPR, i.e., our legal obligation to monitor and implement the international and/or national sanctions.
– Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to fulfil the requirements for money laundering and financing terrorism prevention, prevention of corruption, bribery, and fraud to be legitimate, reliable, and reputable business to our counterparties and authorities.
– Article 6 Part 1. (f) of the GDPR), i.e. our legitimate interest to protect our business interests and defend or enforce legal claims (If you get involved in a dispute with us or we need to otherwise defend, enforce, exercise, and uphold our rights or legitimate interests, we collect, use and store the data that is necessary for the specific case)		 We will process your personal data collected during the Onboarding and Due Diligence Procedure for 5 years after the last Onboarding/Due Diligence procedure, unless longer storage of personal data and related documents will be required by applicable laws, legal regulations, or institutional/state authorities, or will be necessary for the defense in the judicial process.

For more details of personal data processing for onboarding and due diligence please check the Privacy notice

https://klasjet.aero/privacy-notice/
Whistleblowing Policy – prevention of adverse effects to whistle-blower, investigation of disclosure and perpetrated or suspected infringement. We may process name, surname, contact information, position in the company, other information provided voluntarily by a whistle-blower or processed by KlasJet or received from Avia Solutions Group – for the purpose of investigation of the perpetrated or suspected infringement.

In principle, we do not request or process any special categories of personal data (e.g., information about health, racial and/or ethnic origin, religious and/or ideological convictions, trade union membership or sexual orientation), unless such special categories of personal data are voluntarily disclosed by the whistle-blower or other concerned persons.

 

 Your personal data shall be processed in accordance with:

– Article 6 Part 1. c) of the GDPR, i.e., legal obligation to establish an internal reporting channel to which we are subject.

– Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to handle fraud, corruption or other wrongdoings in the Company and to defend against requirements and/or claims and investigations of the competent authorities, litigations (if any) or, if necessary, to keep such data regarding possible investigations on allegedly illegal or criminal acts.

 

 We will process your personal data collected during the whistleblowing procedure no longer than 5 years unless longer storage of personal data and related documents will be required by applicable laws, legal regulations, or authorities, or will be necessary for the judicial process.

For more details of personal data processing for whistleblowing procedure please check the Privacy notice (https://trust-line.aviasg.com/files/privacy_notice.pdf?v=1.0.4)

 
Selection of candidates for employees (recruiting) Considering the requirements of the position applied we may collect, assess, and store the following personal data about you: name, surname, age or date of birth, your e-mail address, phone number, address of the place of residence, information on language proficiency, computer skills, information about expected salary, educational background, profession, working experience and projects you have been involved with, attended courses, training sessions, seminars, development of qualification, licenses held, accumulated hours on A/C and other information regarding flights (for pilots and cabin crew), social media accounts, pictures and other information that you may wish to provide in your CV, motivation letter, interviews, also our remarks and assessment of your suitability to perform the duties of a particular position. We will process the said personal data in accordance with:

– Article 6 Part 1. a) of the GDPR, i.e., with your consent – to the extent described in the relevant consent.

 

– Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest – to have a common and coordinated policy on the selection of personnel and human resources management and to share the information about your candidacy within other Avia Solutions Group companies.

 We will process the personal information for the recruiting process for 6 (six) months from getting your application unless the selection process continues longer than the indicated period.

When you are unsuccessful in your application for a concrete position in a company of Avia Solutions Group you may agree for further sharing your data within all Avia Solutions Group companies. In this case your personal data will be stored for 3 years from the end of selection process for the position you applied or from receiving the data.

 

For more details of personal data processing for selection of candidates please check the privacy notice (https://careers.aviasg.com/en/candidate-privacy-policy).
Performance of the air carriage contract between the passenger and the Company This information applies only to those flights, or flight segment, where KlasJet name or Airline Designator Code KJ or KLJ is indicated in the carrier box of the ticket for that flight, or flight segment.

We may process your personal data such as name, surname, contact details, passport information; visa information, health information (if applicable); flight information (flight number, origin and destination airport, flight date and time), information-related in- flight services (meals), luggage information, seat information, payments information for the purpose of performance of the air carriage contract.

 To complete the air carriage contract, we will process the information in accordance with:

Article 6(1)(b) GDPR – Contract: processing is necessary for the conclusion and performance of the air carriage contract with you;

Article 6(1)(c) GDPR – Legal Obligation: processing is necessary to comply with applicable legal obligations, including those relating to immigration, customs, aviation safety, and border control;

Article 6(1)(f) GDPR – Legitimate Interests: processing is necessary for our legitimate interests, namely the establishment, exercise, or defence of legal claims, where applicable;

Article 9(2)(g) GDPR – Special Category Data (Health Data): where we process information relating to your health (e.g. reduced mobility, special assistance, or medical requirements), such processing is carried out as necessary for reasons of substantial public interest, in particular to ensure aviation safety and to provide the requested air carriage services.

 

 We will retain personal data collected in connection with the performance of the air carriage contract for no longer than five years after the date of the flight, unless longer retention is required by applicable laws, regulations, or competent authorities (for example, aviation safety or accounting record-keeping obligations, in which case data may be retained for up to ten years).

Health-related data provided to enable special assistance or in-flight services will be retained only for as long as necessary to provide the service and for a period not exceeding one year after the flight, unless longer retention is required due to a legal claim.
Recordings of telephone conversations

 

 When you contact us by calling our mobile phone numbers +370 652 09194, +370 655 76178, or +370 655 72232, conversation may be recorded. The following personal data may be collected and processed during these calls: the voices of all participants, the content of the conversation (which may include personal data shared during the call), and metadata related to the recording, such as the phone number used to place the call, the date and time of the call, the duration of the conversation, and any waiting time experienced.

 

 The data of a person who calls the Company on the telephone numbers shall be processed with the consent of that person (Article 6(1)(a) GDPR). Please note that a person may object to the recording of a telephone conversation. During the telephone call, the person shall be informed of his/her right to object and not to continue the call and to contact the Company in other ways (e.g., by e-mail). If the person does not consent to the processing of personal data, the telephone conversation will not be initiated (the person will not be connected to an employee of the Company). The personal data of employees shall be processed on the basis of the Company’s legitimate interest in ensuring the proper provision of air transport services and the traceability of related business processes (Article 6(1)(f) GDPR).

 

 The conversation record shall be retained for 90 calendar days. Where a conversation recording is necessary for the purpose of conducting an investigation, handling a complaint or dispute, it may be kept until it is no longer necessary for the purpose for which it was processed.

If you do not provide personal data, the provision of which to the Company is necessary to ensure compliance with the requirements of legal acts and / or the conclusion and / or performance of the contract, we will not be able to provide you with services or conclude another transaction.

Please know that “Legitimate interest” means our interest to enhance our services, products, to manage the processes of businesses and activities. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Be informed as well that we will retain your personal data for as long as necessary to achieve and fulfil the purposes following the terms set out in this Privacy Policy,  unless longer storage of personal data and related documents is required by applicable laws and regulations or is required for the defense of the Company’s legitimate interests in judicial, other public institutions etc. We ensure and take all necessary measures to avoid storing outdated or unnecessary personal data about you.

HOW DO WE PROTECT YOUR DATA?

We responsibly implement appropriate organisational and technical personal data security measures intended for the protection of personal data against accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The security measures we implement include the protection of personnel, information, IT infrastructure, internal and public networks as well as office buildings and technical equipment.

In the event of personal data breach of security that could seriously jeopardise your rights or freedoms and determine the circumstances with which unauthorised access to personal data has been obtained, we will immediately inform you about it.

TO WHOM IS YOUR DATA ARE DISCLOSED

We may share some of your personal data with the following categories of third parties:

  • any Avia Solutions Group company (listed at https://aviasg.com/en/the-group/general-contacts) for the purposes set out in this Privacy Policy (for the purposes of performance of contracts and the management of relationship with customer, onboarding and due diligence of the counterparty, recruitment);
  • representatives acting on our behalf with respect to the promotion of our services in particular territories;
  • companies providing data centers, hosting, cloud, site administration and related services, software developers, providing, maintaining and developing companies, companies providing information technology infrastructure services, companies providing communication services;
  • credit and debit card companies used to facilitate payment transactions related to the provision of our services, banks and other credit and/or payment companies;
  • airports, ground handling companies, security providers, and in-flight crew;
  • our professional advisors, auditors, lawyers and/or financial advisers;
  • our other service providers (data processors) or our subcontractors;
  • notaries, if the contract concluded with you requires a notarial form;
  • judicial officers, entities providing legal and/or debt recoveries services, subrogator of claim right;
  • companies providing advertising and marketing services;
  • companies providing archiving, physical and / or electronic security, asset management and/or other business services;
  • in accordance with the laws to state institutions, establishments, etc.;
  • law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies; tax administrators
  • in the event of a company restructuring, transfer / acquisition and / or business transfer / acquisition, to a third party acquiring the business and processing personal data for the same purposes as specified in this Privacy Policy and/or doing the Due Diligence by our and/or their legal and/or financial advisors, etc.

DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA

As a general rule, your personal data will be processed in the countries of the European Economic Area (hereinafter – EEA). However, in certain cases, your personal data may be transferred to non-EEA countries. Please note that in non-EEA states, personal data may be subject to less protection than within the EEA, but we carefully evaluate the conditions under which such data will be processed and stored after being transferred to the above-mentioned entities.

Please note that if the European Commission has determined that the third country, territory or one or more specified sectors in that third country or international organization concerned provides an adequate level of personal data protection, the transfer must take place in the same manner as in the EEA. Please be informed that you can have access to the information as to the states in respect of which the decision of the European Commission has been taken, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

In other cases, we take all necessary measures to ensure that your personal data is transferred to the recipient safely processing the data. The tools we use: a contract with a non-European recipient of personal data includes specific clauses for the secure processing of the data. In certain cases, we ask for your consent to transfer your data outside the Republic of Lithuania or the EEA.

DO WE APPLY AUTOMATED DECISION-MAKING OR PROFILING?

We do not normally use automated decision-making under Article 22 of the GDPR to initiate and execute contractual relationships. Should we apply this procedure in individual cases, we will inform you separately, if required by law.

We process your personal data in a partially automated way in order to assess certain personal aspects (hereinafter – Profiling). We use profiling, for example, when we are required by law to prevent money laundering or manage financial risk.

RIGHTS GUARANTEED TO YOU

We guarantee the implementation of these rights and the provision of any related information at your request or in case of your query:

  • know (be informed) about the processing of your personal data;
  • to get access to your personal data which are processed by the Data Controller;
  • request correction or addition, adjustment of your inaccurate, incomplete personal data;
  • require the destruction of personal data when they are no longer necessary for the purposes for which they were collected;
  • request the destruction of personal data if they are processed illegally or when you withdraw your consent to the processing of personal data or do not give such consent, when is necessary;
  • disagree with the processing of personal data or withdraw the previously agreed consent;
  • request to provide, if technically possible, the provision of your personal data in an easily readable format according to your consent or for the purpose of performing the contract, or request the transfer of data to another data controller.

In order to exercise your rights, please send us the request by e-mail: [email protected].

Upon receipt of your request, we may ask you to provide proof of your identity or other identifying information to ensure that we are exercising your rights as a data subject and to prevent unauthorized disclosure of personal data or information to others who are not entitled to it. If we are unable to identify you, we will not be able to exercise your rights as a data subject.

We provide information about the processing of your personal data free of charge. If your request is unfounded, repetitive or disproportionate, we may charge a fee commensurate with our administrative costs.

Upon receipt of your request, we will respond to you within 30 calendar days of receipt of your claim and the due date for submission of all documents necessary to prepare the answer.

In exceptional circumstances, which may require us to have additional time, the deadline for replying may be extended for a further two months, depending on the complexity of the situation. In this case, it is mandatory to inform the Data Subject in writing about such extension within 1 (one) month from the receipt of the request and indicate the reasons for the delay. If we think we need to, we will stop the processing your personal data, except for storage, until your application is resolved. If you have legally waived your consent, we will immediately terminate the processing of your personal data and within no more than 30 calendar days, except in the cases provided for in this Privacy Policy and in the cases provided for by law when further processing of yourpersonal data is binding on us by the legislation in force, the legal obligations we are facing, court judgements or binding instructions from the authorities. The responce will be provided in the same way as your request was received.

By refusing to comply with your requirement, we will clearly indicate the grounds for such refusal.

If you disagree with our actions or the response to your request, you can complain to the competent state authority (the list of supervisory authorities by each EU countries: https://edpb.europa.eu/about-edpb/board/members_en). In all cases, we recommend that you contact us before making a formal complaint so that we can find the right solution.

WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?

We may, from time to time, expand or reduce the scope of our business operations and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this notice, be permitted to use that data only for the same purposes for which it was originally collected by us.

LINKS TO OTHER WEBSITES

Our Websites may contain links to other websites, which are not operated by us. We have no control over how your data is collected, stored, or used by such other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

SOCIAL NETWORKS

When you visit social networks, your personal data is processed by a specific social network, and we start processing your personal data when you visit KlasJet on social networks. Through various social media channels, we want to introduce you to our wide range of services / products and exchange ideas and opinions with you on important topics.

Your personal data provided on the social network is processed for the following purposes:

  • communicate with our social network visitors;
  • respond to visitor inquiries;
  • obtaining statistical information;
  • conducting customer surveys, marketing campaigns, market analysis, lotteries, competitions or similar actions or events;
  • if necessary, defending the legitimate interests of the Company in institutions and in other cases;

Unless explicitly stated otherwise, the legal basis for data processing is Article 6 part 1 point (f) of the GDPR. Our legitimate interests are to be able to answer your messages or questions and analyze our availability on social networks, to present our products and services. To the extent that you wish to enter into a contractual relationship with us with your request, the legal basis for such processing is Article 6 part 1 point (b) of the GDPR.

If we intend to process your personal data for any other purpose not mentioned above, we will notify you prior to such processing.

Our pages on social networks are managed by specific social networks, so when you visit them, the processing of personal data is based on the social network privacy policies. With some social networks, depending on the social network policy, the purposes and scope of the processing, we are considered as joint data controllers.

Currently we use these social networks:

Facebook: https://www.facebook.com/klasjet

Instagram: https://www.instagram.com/klasjet/

LinkedIn: https://www.linkedin.com/company/klasjet/

YouTube: https://www.youtube.com/@klasjet

TikTok: https://www.tiktok.com/@klasjet

Name of the social network and its Privacy Policy Personal Data we process Personal Data we process as joint data controllers
Facebook

You can read their privacy policy by clicking here: https://www.facebook.com/policy.php

 

 Your Facebook username, when you comment, react to the publication, share posts, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more. We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Facebook through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum
Instagram

You can read their privacy policy by clicking here: https://help.instagram.com/519522125107875/?helpref=uf_share

 

 Your Instagram username, when you comment, react to the publication, share posts, share content in stories section, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more. We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Instagram through their service. The data controllers’ agreement can be found here: https://help.instagram.com/494561080557017/?helpref=hc_fnav
LinkedIn

You can read their privacy policy by clicking here: https://www.linkedin.com/legal/privacy-policy

 Your LinkedIn username, when you comment, react to the publication, share posts, write us messages, Your location indicated on the personal account, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more. We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from LinkedIn through their service. The data controllers’ agreement can be found here: https://www.linkedin.com/legal/l/dpa
YouTube

You can read their privacy policy by clicking here:  https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/

 Your YouTube username, when you comment, interact with content. If you are logged in with YouTube, you agree to YouTubes terms of use, privacy and cookie policies and to YouTubes processing of your personal data, at which we have no control over. If you are not registered with YouTube, YouTube may still perform statistical analysis of your personal data when you access our YouTube channel and provide us with anonymized statistics on this.

We use statistical information. Processed data types:

– Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers);

– Content data (videos etc.);

–  Usage data (e.g. websites visited, interest in content, access times, video views, video likes, comments, purchases etc.), meta/communication data (e.g. device information, IP addresses).

Video Statistics:

– Number of subscribers and changes

– Watch time data (duration, stoppage time, retention rate)

– Demographics (gender distribution, age, places of origin, use of devices etc.)

We receive anonymous statistics from Youtube through their service. The data controllers’ agreement can be found here: https://business.safety.google/controllerterms/

 
TikTok

You can read their privacy policy by clicking here:  https://www.tiktok.com/legal/page/row/privacy-policy/en

 Your TikTok username, when you comment, interact with content. We use statistical information.

We receive anonymous statistics from Tiktok through their service.

TikTok collects this data:

– The videos you watch and rewatch

– The videos you comment on

– The keyboard rhythms you have when you type

– Your phone and location data

– Clipboard data

– Private messages and contacts

– Any information you share while creating your account

– Information from linked social media accounts.

The data controllers’ agreement can be found here: https://ads.tiktok.com/i18n/official/article?aid=998850064133680764

 

CHANGES TO OUR PRIVACY POLICY

We reserve a right to change this Privacy Policy unilaterally from time to time (for example, if the law changes). Any changes will be immediately posted on our websites. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy applies from the date it is posted on the Websites. Last review of the Privacy Policy: 25.11.2025. If you continue to use our services (such as the Website) after changing the terms of the Privacy Policy, you will be deemed to have read and understood the changed terms of the Privacy Policy.